The Mumbai Tribunal in Maharashtra State Electricity Board v. DCIT (83 TTJ 325), examined applicability of the old India-UK Double Tax Avoidance Treaty (DTAA), which was substituted by new DTAA in 1994, to fees received by a UK-based firm of solicitors for legal services provided to an Indian company
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap